Eduardo C. Bautista v. Pan American World Airways, Inc.

Summary

Former Pan American World Airways catering employees sued Pan Am for breach of collective bargaining agreements, the Transport Workers Union for breach of its duty of fair representation, and Marriott for tortious interference with contractual relations. The Ninth Circuit affirmed summary judgment for the union, held that the Railway Labor Act deprived the district court of jurisdiction over the contract claim against Pan Am, and remanded the claim against Marriott to determine whether diversity jurisdiction existed. The court did not decide whether the collective bargaining agreements created a right to lifetime employment.

Holdings

1. The union did not breach its duty of fair representation because its decision to renegotiate the no-layoff guarantees in light of Pan Am's sale of the catering operations fell within the wide range of reasonableness afforded to unions bargaining on behalf of their membership as a whole.
2. The alleged statements that the employees' jobs were protected did not establish a duty-of-fair-representation violation because they represented the union official's interpretation of an ambiguous provision rather than an intentional fabrication designed to mislead the membership.
3. The district court lacked jurisdiction over the employees' claim against Pan Am because the claim was a dispute concerning the interpretation or application of a collective bargaining agreement within the exclusive jurisdiction of the National Railroad Adjustment Board, and the Glover exception did not apply after the union claim failed.
4. The district court could not properly decide the preemption issue without first determining whether it had subject-matter jurisdiction over the state-law claim against Marriott.

Questions Presented

1. Whether the Transport Workers Union breached its duty of fair representation by agreeing to abolish the no-layoff guarantees and by allegedly making misleading statements about job protection during the strike.
2. Whether the district court had jurisdiction over the employees' breach-of-collective-bargaining-agreement claim against Pan Am under the Glover exception to the Railway Labor Act's exclusive administrative-remedy scheme.
3. Whether the district court properly held the employees' state-law tortious-interference claim against Marriott preempted without first determining whether diversity subject-matter jurisdiction existed.

Disposition

other